Corrective Action Plans

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

The District has existing policies to address overdue meal charges: EFAA-Meal Charging and EFC-Free and Reduced-Price Lunch. Due to staff transitions over the last several years, these policies have not been adequately enforced. The following steps will be taken to correct this: • Central Office Oversight: The central office will take a more active role in ensuring policies are executed effectively. • Policy Review: Policies will be reviewed with all staff members responsible for their implementation. • Targeted Training: Comprehensive training will be provided to all involved personnel, specifically food service workers and building principals. • Compliance Monitoring: The central office will monitor adherence to these policies and provide ongoing support to staff. • Community Partnership: The District will increase coordination with non-profit charities to secure assistance for students in need. Additionally, current policies and practices will be reviewed and updated as necessary to ensure the desired outcomes are achieved.

To prevent future errors in reporting, the School District will establish a simple monthly reconciliation procedure in which reported meal counts are compared to daily meal service records to identify and correct discrepancies before submission.

To prevent future errors in eligibility determinations, the School District will implement a secondary review process. All eligibility applications will be reviewed by a second qualified staff member to verify household size, income calculations, and comparison to the National Income Eligibility Guidelines before final approval.

Finding 2025-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. The lack of review was isolated to fiscal year 2024 as the School Corporation qualified under the Community Eligibility Provision for fiscal year 2025. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the event the School Corporation is not eligible for the Community Eligibility provision in future periods, the Treasurer and Food Service Director will develop controls to ensure system income thresholds are reviewed annually to ensure they are in agreement with USDA income thresholds. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for ensuring system income thresholds are met.

Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Questioned Costs: $164,866 (known questioned costs) Context: During the testing of meal claim reimbursements, we noted 3 monthly reimbursements in a sample of 6 claims selected where the School Corporation was unable to produce auditable support of meals served and claimed via underlying meal system reports. The claim reimbursements for these 3 months unsupported by meal claim data totaled $157,708. Additionally, we noted one month in which there were variances when comparing the reimbursement in our to sample to underlying meal system reports, resulting in $7,158 over claimed. Additionally, we noted that management has no formal, documented review control in place for monthly meal claims prior to submission to the Indiana Department of Education (IDOE). Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer and Food Service Director will enhance internal controls surrounding the Child Nutrition claim reporting process. The Treasurer and Food Service Director will ensure the preparation and review of claims is documented and correct prior to submission. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for the claim reporting process.

Response and Corrective Action Plan: The District will review its procedures and look into possible additional controls to be implemented.

Compliance Requirement Procurement Criteria Under 2 CFR 180.995, the School District must not enter into covered transactions with parties that are suspended or debarred. For covered transactions (generally at or above the simplified acquisition threshold), the School District must verify that vendors are not suspended or debarred by (1) checking SAM.gov, (2) collecting a vendor certification, or (3) adding a contractual clause that the vendor is not suspended or debarred and maintaining documentation of the verification. Additionally, under 2 CFR 200.318(h), the School District must maintain effective internal controls over procurement to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition During testing and confirmed with management at the School District, it was determined that the School District does not verify that vendors were not debarred or suspended. Cause The School District’s procurement procedures do not require or are not consistently followed to perform and retain documentation of suspension and debarment checks for covered transactions. Effect Without controls to verify and document vendor eligibility, the School District is at risk of expending federal funds with vendors that are suspended or debarred, resulting in noncompliance with federal requirements. This could lead to questioned costs, repayment obligations, and reputational risk. Recommendation The Bonadio Group recommended that the School District strengthen its internal controls over the procurement requirement regarding suspension and debarment requirement by implementing the following actions: (a) Update written procurement procedures to clearly require documented verification before entering any covered transactions. (b) Require procurement staff to document verification at the time of award and to retain the documentation in the procurement file. (c) Integrate a system of controls, where feasible, that prevents a purchase order or contract from being finalized unless proof of suspension/debarment verification has been uploaded. (d) Provide reoccurring training to procurement, finance and grant management staff regarding federal suspension and debarment requirements and proper documentation practices. (e) Implement periodic monitoring or internal reviews to ensure that the verification process is consistently followed and address any deviations promptly. View of Responsible Officials The School District will institute additional procedures to ensure that vendors are not debarred or suspended. Response We are in agreement with the recommendation and will be creating a federal funds procedural manual to address the issues above. Anticipated Completion Date This will be corrected by 6/30/26. Person Responsible Stephanie Fanning, Assistant Superintendent for Business

Date: February 9, 2026 FINDING 2025-001 Finding Subject: Child Nutrition Cluster-Eligibility Contact Person Responsible for Corrective Action: Paula Powers, Food Service Coordinator Contact Phone Number and Email Address: 812-347-3905 ppowers@nhcs.k12.in.us Views or Responsible Official: We concur with the findings. Description of Corrective Action Plan: With future processing of Direct Certification downloads, the Food Authority will generate and IT department will input Direct Certification to software System (Harmony). A second person will review the approval process to ensure Direct Certification input was downloaded correctly. After reviewing, second person will sign the Direct Certification download list in order to maintain proper checks and balances. Anticipated Completion Date: August 2026

Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness Condition : An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirements. Context : During testing of internal controls over eligibility requirements, we noted there is no formal, documented review of the eligibility income guidelines entered into the food service software to ensure that system parameters were in agreement with USDA guidelines on an annual basis. For the 2023-2024 school year, the income eligibility guidelines were not updated timely by the School Corporation. During compliance testing of eligibility, we noted 3 instances isolated to 2023-2024, in a sample of 60 students, in which the eligibility status was incorrectly determined. In two instances, the eligibility status was changed from Reduced to Free upon updating the eligibility income guidelines. In one stance, the status changed from Pay to Reduced. The lack of internal controls over the review of the eligibility income guidelines impacted both years under audit. The noncompliance with eligibility determinations was isolated to fiscal year 2024. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : The Student Management Specialist will print the thresholds and enter the eligibility income guidelines into the food service management software, Harmony. The Superintendent will verify that the data has been entered correctly. Responsible Party and Timeline for Completion : This has already been implemented.

Information on the federal program : Subject: Child Nutrition Cluster (CNC) Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed and Unallowed, Allowable Costs Audit Findings: Material Weakness, Other Matters Condition : The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context : During our testing of the School Corporation’s compliance with the allowable cost requirements for the Child Nutrition Cluster (CNC), we tested 40 vendor disbursement transactions and 40 payroll disbursement transactions and identified the following exceptions: 1. For one vendor disbursement, the School Corporation incorrectly recorded the disbursement for $820 to Fund 800 (School Lunch Fund) that should have been recorded to Fund 300 (Operations Fund), resulting in an unallowable cost being charged to the food service fund. 2. For one payroll disbursement, the School Corporation inaccurately entered the number of hours worked by a cafeteria employee for one pay period, resulting in an overpayment to the employee by $5,568. The employee notified the School Corporation of the overpayment and remitted the overpayment back to the School Corporation. These errors were attributable to deficiencies in the internal controls over the review and approval of vendor and payroll expenditures. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : Management will enhance controls and review processes surrounding vendor and payroll expenditures charged to the Child Nutrition. The Food Service Director will be receiving periodic reports to review expenditures charged to the CNC to monitor charged costs. The payroll exceptions report is now checked by the Executive Assistant and Payroll. Responsible Party and Timeline for Completion : Immediately corrected

We will make sure that multiple employees are trained in and have the knowledge of federal compliance requirements so that if one employee is absent for any reason another employee will have the ability to complete the claim for reimbursement in a timely manner to remain in compliance with the Child Nutrition Cluster program requirements.

We will make sure that multiple employees are trained in and have the knowledge of federal compliance requirements so that if one employee is absent for any reason another employee will have the ability to complete the claim for reimbursement in a timely manner to remain in compliance with the Child Nutrition Cluster program requirements.

FINDING 2025-004 CNC Procurement and Suspension and Debarment Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Accounting Department will start keeping a binder that will include all the Procurement and Suspension and Debarment Certificates pertaining to the vendors in our federal programs, which includes Child Nutrition, that equal or exceed $25,000 for each school year. The A/P Clerk will alert the Treasurer when a certificate is needed, and the Treasurer will first check SAM, and then proceed with collecting a certificate from the vendor if one is not found online. When applicable, we can add a clause or condition to a contract noting this acknowledgement. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

FINDING 2025-003 CNC Eligibility Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Direct Certification downloads will be done once a month by the Cafeteria Director. The Cafeteria Director will sign the report and forward it to the Treasurer for verification and a second signature. The Direct Certification reports will be kept at the central office. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Views of Responsible Officials and Corrective Action Plan: School Corporation has implemented procedures to ensure a complete record is maintained for every free and reduced-price meal application and any subsequent eligibility status change. All applications, supporting documentation, and determination records are retained as hard copy files. An electronic Benefit Issuance Document will also be retained during the year and printed as a hard copy record. Any change in eligibility status is documented with the effective date and supporting rationale to provide a clear audit trail. These procedures are now part of the School Corporation’s standard operating practices in school food service to ensure ongoing compliance and continuity moving forward. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

Corrective Action Plan: The Division will implement a review process to ensure the accuracy of the inventory management and reporting process. Anticipated Date: April 2026 Name of Person Responsible for Implementation: Al Agpoon, Controller

Program: AL 10.553 – School Breakfast Program; AL 10.555 – National School Lunch Program; AL 10.556 – Special Milk Program for Children; AL 10.559 – Summer Food Service Program for Children; and AL 10.582 – Fresh Fruit and Vegetable Program – Reporting Corrective Action Plan: On February 25, the NDE grants management team completed a crosswalk that matches the coding in the E1 payment system with the grant award FAINs the sam.gov system recognizes. Next, the data management team will query the E1 payment system to generate a report with correct FAINs needed for reporting; this will be completed by March 2, 2026. Finally, the Nutrition Services team will review the reports and will complete submission of missing reports using the corrected data files by March 31, 2026. Contact: Kayte Partch Anticipated Completion Date: March 31, 2026

Reference # and title: 2025-001 Untimely Completion of Time Certifications Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2025 National Lunch Program 10.555 2025 Condition found: Federal regulations require that salaries and wages charged to federal programs be supported by time and effort documentation that accurately reflects the work performed and is completed in a timely manner, in accordance with 2 CFR §200.430. In testing a sample of Child Nutrition payroll, it was noted for all eleven employees tested, the Child Nutrition Program did not complete required time certifications in a timely manner. Several certifications were completed after an extensive amount of time, resulting in noncompliance with federal documentation requirements. Corrective action planned: The School Board has changed when the time certifications are completed to comply with the federal requirements. The School Board will implement written procedures to address the issue. Management will review and monitor the process to ensure compliance with the new procedures.

Reference # and title: 2025-004 Internal Control over Allowable Costs Federal program and specific federal award identification: AL # Grant Year FEDERAL GRANTOR/ PASS-THROUGH GRANTOR/PROGRAM NAME Passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2025 National School Lunch Program 10.555 2025 Summer Food Program 10.559 2025 Criteria or specific requirement: 2 CFR section 200.430(g) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on a Federal award and a non-Federal award. Condition found: No time certification was completed by Child Nutrition Supervisor for six months of the year. The Child Nutrition Supervisor retired in December 2024. Corrective action plan: Make a list of all employees who are paid by two budgets and require them to complete and sign time and effort sheets monthly. Person responsible for corrective action: Supervisors Anticipated completion date: Time and effort reports are to be reviewed monthly by supervisor and time and effort reports are to be kept on file by individual supervisors beginning school year 2025-2026.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the findings Response Comments: According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This will need to voted on by the School Board before we can put into practice. Anticipated Completion Date: August 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will design and implement a proper system of internal controls and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering any contracts or subawards. This process will include obtaining vendor certifications and/or verification through SAM.gov, with two independent individuals reviewing and confirming the completeness and accuracy of the documentation. Certification will be initialed and retained in the procurement file. Anticipated Completion Date: January 26, 2026 INDIANA STATE

The District acknowledges the finding regarding inaccuracies in meal counts reported for the Child Nutrition Program reimbursement claims. To address this issue, the District will strengthen internal controls over the meal count reporting and claim preparation process. The food service department will ensure that daily meal count documentation is properly maintained and reconciled to the monthly claim totals prior to submission. In addition, the Director of Business Operations will implement a formal management review process prior to submission of each monthly claim for reimbursement to the Arizona Department of Education. This review will include verification that reported meal counts agree to supporting documentation and that all reconciliations have been completed and documented. Any discrepancies identified during the review will be investigated and corrected before the claim is submitted. These procedures will provide additional oversight and help ensure the District maintains compliance with federal regulations and the reporting requirements of the Child Nutrition Program. The Director of Business Operations is responsible for implementing and monitoring this correction action, which will be completed at the end of the next fiscal year.

Management concurs with the finding and will implement corrective actions to improve claim review procedures and staff training to ensure future reimbursement submissions are accurate and compliant.